ML20238B194

Forwards Mn Christensen to Author Informing of Steps Taken to Correct Violations Noted in NRC . Corrective Actions:Frequency of Reactor Operations Audits Corrected & Personnel Advised of Reporting Requirements

ML20238B194
Person / Time
Site:	Berkeley Research Reactor
Issue date:	08/20/1987
From:	Pigford T CALIFORNIA, UNIV. OF, BERKELEY, CA
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8709010109
Download: ML20238B194 (4)

Text

w UNIVERSITY OF CALIFORNIA. BERKELEY M

RA

, BERKELEY

• DAVI5

• TRVINE

• LOS ANCELES

• RIVERSIDE

• SAN DIEGO

• SAN FRANCISCO i

SANTA BARBARA. SANTA CRUZ COLLEGE or ENGINEERING BERKELEY, CALIFORNIA 94720'.

DEI *ARTMENT OF NUCLEAR ENGINEERING

. August 20, 1987-Docket.No. 50-224 License No. R-101 U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D. C.

20555 Subj ect : Reply to NRC Region V Notice of Violation Dated July 29, 1987

Dear Sir:

This letter is to reply to a Notice of Violation dated July 29, 1987 to the recent NRC Region V inspection to our f acility.

A.

Technical Specifications, Section 6.2(c) states in part:

"The Reactor Hazards Committee or a Subcommittee thereof shall audit reactor operations at least quarterly but at intervals not to exceed four months."

Contrary to the above, Reactor Hazards Committee audits of reactor operations were not performed for the first and second quarters of 1986 covering a span of more than ten months.

This is a Severity Level IV Violation (Supplement 1).

Response: See attached letter of August 17, 1987 from Professor Mark N. Christensen, Chairman, Reactor Hazards Committee.:

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gg*AM Bn8lir 36

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U. S. Nuclear Regulatory Commission Page hto August 20, 1987 B.

Technical Specifications, Section 6.7(c)(4), requires a written report be submitted to the NRC within 30 days of any observed inadequacies in the implementation of administrative 'or procedural controls.

Contrary to the above, a 30-day report for failure of the Reactor llazards Committee to conduct the first and second quarter audits of 1986, spanning a period of more than ten months, had not been initiated as of July 31, 1987.

i This a Severity Level IV Violation (Supplement 1).

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i Response: See attached letter of August 17, 1987 from Professor i

Mark N. Christensen, Chairman, Reactor llazards Committee.

l Respectfully yours, l'

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,,y.J k, l'i.

i Thomas 11. Pigford Reactor Administrator TilP/jmh At t achment

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cc: Dean Pister, College of Engineering, w/ attachment Professor Christensen, Chairman, Reactor llazards Committee, w/ attachment Regional Administrator, Nuclear Regulatory Commission, Region V, w/ attachment

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f Lv s

l UNIVERSITY OF CALIFORNIA, BERKELEY b

I BERKELEY

• DAVIS

• IRVINE

• LOS ANCELES

• BJVERSIDE

• SAN DIECO

• SAN FRANCISCO SANTA BARBARA

• SANTA CRL'1 k

6, I

ENERGY AND RESOURCES PROGRAM RM.112, DLD'C. T-5 BERKELEY, CALIFORNIA 94720 j

Augrst 17. 1987 Prof. Thomas Pigford Reactor Administrator Nuclear Engineering j

Campus Re: Reply to Notice of Violation

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Dear Prof. Pigford:

I send.this letter to be included in your reply to the recent NRC Inspection l

of TRIGA facility. The letter from F.A. Venslavski to Dean Pister, dated i

July 29, 1987, notes two violations for which I, as Chairman of the Reactor Hazards Committee, am responsible.

Two related viola; ons are noted: 1) that "...RHC audits.of reactor operations were nu, performed for the first and second quarters of 1986..."

and 2) that "...a 30-day report for failure of the IHC to conduct the Violation 1-failure,to perform audits:

1) Reasons: a) One member of the Committee, Professer Cann of UCSF, failed to perform an audit which he repeatedly committed hi'nself to, vent on i

sabbatical leave and withdrev from the Committee vithout notice.

It took I

some time to ascertain that he could not be expectect to perform the audit.

Professor Buxbaum was Chairman of the Committee at t hat time; this sequence of events took place as the end of Professor Buxbaur's term approached and he was preparing to go on sabbatical leave.

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b) Professor Bauxbaum himself was scheduled to perferm the subsequent audit. He was hit with unexpected workload as he piepared to leave.

He notified me in timely fashion that he vould be unable to perform the audit as scheduled. During the summer of 1986, when this occurred, I was away from campus for extended periods; also there was de]ay in my appointment as Cha.'.rman of the Cownittee. By the time I was back on campus, properly appointed as Chairman, and prepared to take action 1o remedy the lapses, the end of the second quarter had passed.

2) Corrective Steps: The Committee doubled the number of audits in two subsequent quarters, so that the total number of auc'its performed nov l

corresponds to the specified numbered.

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3) Heasures to Avoid Future Violations.

If written audit reports, or firm assurances of delivery, are not in hand two weeks before quarter's end, responsibility for the audit vill be reassigned.

Following the suggestion i

of Inspector Cillis, ex officio members of the Commfttee may be assigned to audit aspects of operations that are outside the.ir own responsibility.

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4) Compliance is already as full as it can ever be.

No direct remedy for tardiness is available.

Violation 2 - Failure to report

1) Reason: My lack of familiarity with Tech Specs, Sec 6.7(c)(4), the f

reporting requirement. That requirement provides a simple, straightforward

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vay to deal vith the probleu of missed audits. The Committee was highly j

agitated about the missed audits, and pressed to male-up the missing i

audits, but the reporting requirement did not occut to me--or to any of the

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other members of the Committee.

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2) Corrective Steps: The Reactor staff and I are now all keenly aware of the reporting requirement, as a simple, straightforward way to deal with problems of this sort. Inspector Cillis's pointing out of the requirement is sufficient to achieve the specified results.

3) Steps to Avoid further violations: same as item 2).

4) Date of full compliance. This letter, I believe, should bring us into full compliance.

In retrospect, tighter procedures o'n checking progre.ss of audits could have l

avoided most but not all of the problems with violation #1. The simple act of reporting #1, as specified in the Tech Specs, would easily and constructively resolved both #1 and #2.

I think ve have learned a useful lesson.

Res ec fully yours,

/ W (( /

?M &

dr risten en Chairman, REC cc. Dean Pister Dr. T. Lim, Reactor Supervisor 2